State of West Virginia v. Jason Devon Saunders
16-0893
| W. Va. | Sep 25, 2017Background
- Motel employees found a grocery bag containing heroin and a PA ID on the motel front desk; an unknown male later took the bag and left the motel office. Employees called police.
- Police matched the motel registry to petitioner Jason Devon Saunders, obtained a recent photo from his federal probation officer, and the employees identified Saunders as the man who seized the bag.
- Officers went to Saunders’ motel room; a woman admitted them, they heard toilet flushing and movement in the bathroom, and Saunders then emerged from the bathroom. Officers entered the bathroom without a warrant and observed heroin in the toilet and on the floor.
- After the warrantless entry, officers obtained a search warrant for the room; Saunders was later indicted for possession with intent to deliver heroin and moved to suppress evidence, arguing the affidavit contained falsehoods and lacked probable cause.
- The circuit court denied the suppression motion (finding one false statement struck but remaining facts supported probable cause and, alternatively, exigent circumstances justified the warrantless entry). Saunders entered a conditional guilty plea reserving the right to appeal the suppression ruling.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Saunders) | Held |
|---|---|---|---|
| Sufficiency of warrant affidavit/probable cause | Affidavit (minus one false statement) contained sufficient facts (employee ID of Saunders, heroin found, presence in bathroom) to establish probable cause | Affidavit was inadequate; eyewitness IDs unreliable and affidavit contained misrepresentations | Court affirmed: after striking one false statement, remaining allegations suffice for probable cause under totality of circumstances |
| Alleged intentional false statements in affidavit | Any falsehoods were not material; warrant still supported by remaining facts | Affiant knowingly or recklessly included false statements (e.g., that the unknown male returned to Room 63; single-photo ID) undermining warrant | Court applied Lilly test, struck the one false statement, found no preponderance showing intentional/reckless falsity that negated probable cause |
| Lawfulness of warrantless entry/search (exigent circumstances) | Officers reasonably believed evidence was being destroyed when they heard toilet flushing and observed movement; exigency justified entry | Entry was unlawful; officers should have obtained a warrant before searching room/bathroom | Court held exigent-circumstances exception applied (based on Dorsey and totality of circumstances): entry/search justified to prevent destruction of evidence |
| Suppression remedy given conditional plea | State urged denial of suppression; conviction permitted under plea reservation | Saunders reserved right to appeal suppression; sought suppression of evidence used against him | Court affirmed denial of suppression; conditional plea preserved appeal but did not alter suppression analysis |
Key Cases Cited
- State v. Lilly, 194 W.Va. 595, 461 S.E.2d 101 (1995) (standard for challenging warrants for false statements and omissions; strike falsehoods and assess remaining probable cause)
- State v. Dorsey, 234 W.Va. 15, 762 S.E.2d 584 (2014) (toilet flushing and movement justified warrantless entry under exigent circumstances to prevent destruction of drugs)
- State v. Kendall, 219 W.Va. 686, 639 S.E.2d 778 (2006) (exigent-circumstances exception is narrowly drawn; permits warrantless entry when quick action necessary)
- State v. Casdorph, 159 W.Va. 909, 230 S.E.2d 476 (1976) (totality-of-the-circumstances test for reliability of out-of-court identifications)
- State v. Lacy, 196 W.Va. 104, 468 S.E.2d 719 (1996) (standards of review for suppression rulings; deference to circuit court factual findings)
- State v. Thomas, 187 W.Va. 686, 421 S.E.2d 227 (1992) (magistrates get deference; probable cause assessed by totality of the circumstances)